November 21, 2001
Mr. Thomas J. Sugrue
Chief, Wireless Telecommunications Bureau
Federal Communications Commission
445 12th Street, SW
Washington, DC 20554
Re: Eliminating CMRS-Public Safety Interference in the 800 MHz Band and
Allocating Additional Spectrum to Meet Critical Public Safety
Communications Needs
Dear Mr. Sugrue:
Nextel Communications, Inc. (“Nextel”) hereby submits the attached White
Paper, “Promoting Public Safety Communications: Realigning the 800 MHz Land
Mobile Radio Band to Rectify Commercial Mobile Radio – Public Safety Interference
and Allocate Additional Spectrum to Meet Critical Public Safety Needs.” The White
Paper recommends that the Federal Communications Commission (the “Commission”)
initiate expeditiously a rulemaking proceeding to accomplish two pressing public interest
goals: (1) making additional spectrum available for public safety communications
services; and (2) substantially reducing interference to public safety communications
from the operations of Commercial Mobile Radio Service (“CMRS”) systems in the 800
MHz band.
Nextel shares the 800 MHz band with Public Safety communications systems,
Business/Industrial Land Transportation (“B/ILT”) licensees, Specialized Mobile Radio
(“SMR”) operators and Cellular Radiotelephone (“cellular”) systems. Cellular licensees
occupy the upper portion of the 800 MHz band directly adjacent to public safety
communications systems. Nextel, other SMRs, B/ILT, and Public Safety systems are
licensed in the 36 MHz of Land Mobile Radio spectrum at 800 MHz adjacent to the
cellular licensees. Nextel is the leading commercial licensee in the Land Mobile Radio
band with licenses for more than 18 MHz of this spectrum.
Over the past two years, Nextel has worked with the public safety community to
identify why CMRS operations are interfering with public safety communications
systems in the 800 MHz band, even though all licensees are in compliance with the
Commission’s rules and the terms and conditions of their licenses. Typically,
interference occurs in the immediate vicinity of CMRS base stations operated by either
the cellular licensees or advanced SMRs using digital, cellular-like network architecture.
Public safety communications operators in about 25 metropolitan areas have experienced
this type of interference, often near multiple CMRS base stations. Interference can
disrupt critical life safety communications with police officers, firefighters, rescue teams
and other emergency response personnel, potentially putting them at risk as well as the
public they serve. Mitigating these risks is essential and has become even more urgent in
the aftermath of the September 11, 2001 terrorist attacks on our country.
Last January, Nextel and the Association of Public Safety Communications
Officials, Motorola, Inc., the Cellular Telecommunications and Internet Association and
the Public Safety Wireless Network presented to the Commission a “Best Practices
Guide” that identified the causes of CMRS – public safety interference and presented
both mitigation alternatives and prior coordination plans to prevent interference. As
discussed therein, the fundamental cause of this interference is an 800 MHz spectrum
allocation plan, initially adopted in 1974, that has failed to keep pace with the dynamic
nature of the wireless telecommunications marketplace. It results in the Commission
authorizing public safety communications providers and CMRS licensees to operate
essentially incompatible systems on mixed, interleaved and adjacent 800 MHz channels.
The locally stronger transmissions of CMRS systems “overpower” less robust, distant
public safety signals -- a signal strength disparity that under certain circumstances causes
interference in the front end of public safety receivers. Intermodulation is the dominant
cause of interference, with wideband noise and receiver overload playing a secondary
role.
Nextel has devoted substantial resources to identifying the causes of CMRS –
public safety interference and developing both immediate and long-term corrective
measures. This White Paper urges the Commission to implement an effective, long-term
solution: an 800 MHz spectrum realignment to relocate public safety and CMRS systems
to separate spectrum blocks, thereby eliminating the mixed licensing of incompatible
system designs that is the underlying cause of CMRS – public safety interference. It
would establish a 20 MHz spectrum block for public safety communications – more than
doubling the current public safety allocation of 9.5 MHz at 800 MHz -- and a separate 16
MHz spectrum block dedicated to advanced, frequency reuse digital SMR networks. The
proposed public safety channel block would be adjacent to television channels 68 and 69,
which have already been allocated for use by public safety communications systems,
ultimately creating a near-contiguous 44 MHz channel block dedicated to public safety
communications uses. B/ILT licensees currently operating on the new public safety
block would become secondary and would be permitted to relocate to spectrum in the 700
MHz and 900 MHz bands on a voluntary first-come, first-served basis.
To implement the proposed band plan, Nextel would swap 16 MHz of spectrum it
currently holds in the 700, 800, and 900 MHz bands; 8 MHz of this spectrum is in the
800 MHz band and would be reallocated to the new public safety spectrum block, while
the other 8 MHz of spectrum is in the 700 and 900 MHz bands and would be used to
relocate B/ILT licensees and high site SMR licensees currently operating in the 800 MHz
band. In exchange, the Commission would grant Nextel licenses for 6 MHz of
replacement spectrum in the new digital SMR channel block at 800 MHz (contiguous to
the 10 MHz already licensed to Nextel in this block), and 10 MHz of unused contiguous
spectrum reallocated for terrestrial commercial use in the 2 GHz Mobile Satellite Service
(“MSS”) band. No incumbent licensee would lose any spectrum, and public safety
operators would obtain additional, critically needed spectrum for increased capacity,
advanced services and enhanced interoperability.
Nextel is willing to contribute up to $500 million to help fund the costs of
relocating incumbent 800 MHz public safety systems in accordance with the realigned
band plan. It would also fund its own significant relocation requirements. Nextel would
provide these funds contingent upon: (1) the FCC’s adoption of the proposed realignment
plan by a Final Order; and (2) the assignment to Nextel of licenses for 6 MHz in the new
800 MHz digital SMR band (in addition to the licenses Nextel currently holds in that
band) and for the 10 MHz, 2020/2025 – 2170/2175, from the MSS band in exchange for
the 16 MHz of spectrum Nextel would surrender as part of the plan. The cellular
operators, and all other CMRS licensees that will benefit from the proposed realignment,
should contribute substantially to the costs of relocating public safety licensees.
The White Paper proposal will help police, firefighters, and other public safety
agencies meet the unprecedented challenges they now face in protecting our nation’s
security, while enhancing the spectral operating environment for public safety and CMRS
licensees. The Commission should expeditiously commence a rulemaking proceeding to
advance these vital public interest measures.
Respectfully submitted,
NEXTEL COMMUNICATIONS, INC.
__________________________________
Robert S. Foosaner
Senior Vice President and
Chief Regulatory Officer
Lawrence R. Krevor
Vice President – Government Affairs
2001 Edmund Halley Drive
Reston, VA 20191
Enclosure (703) 433-4141
Mr. Thomas J. Sugrue
November 21, 2001
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